View original document

The full text on this page is automatically extracted from the file linked above and may contain errors and inconsistencies.

FRBSF Economic Letter
2019-10 | April 1, 2019 | Research from the Federal Reserve Bank of San Francisco

Banks’ Real Estate Exposure and Resilience
Simon Kwan
Real estate has hit record high prices and elevated valuations in some markets. Do bank
lenders have sufficient capital to withstand a large price drop? While their portfolios have a
similar concentration in real estate as they did before the global financial crisis, both
underwriting standards and capitalization have improved significantly since then. Estimates
using the Federal Reserve’s stress test scenarios suggest that, although a few small banks
would be undercapitalized, the banking sector overall appears resilient enough to weather a
steep decline in real estate prices.

Almost all depository institutions lend in the residential or commercial real estate markets and thus are
exposed to declines in real estate prices. This exposure, combined with current house prices surpassing their
pre-crisis peak and commercial real estate prices reaching record high levels, raises some questions about
how much risk banks currently face from these markets.
This Economic Letter examines the capital adequacy of banks to weather a large decline in real estate prices.
Since the Federal Reserve evaluates this risk for the largest banking institutions, I use a loss rate similar to
that used in the Fed’s stress tests to evaluate smaller bank real estate portfolios. My estimates suggest that
only a small fraction of banks would be undercapitalized as a result of the hypothetical real estate loan losses
in their loan portfolios.

Concentration of real estate in bank portfolios
With the current high prices, a number of real estate valuation indicators have signaled growing risk or
“frothiness” in certain market segments. For example, the capitalization rates—the ratios of operating
income relative to the sale price of commercial properties—have reached historical lows for multifamily
residential and industrial commercial real estate. In the residential real estate market, the price-to-rent
ratios in Los Angeles, Miami, and Denver are 10 to 20% above their long-run trends, compared with 4% at
the national level (Brainard 2018). Regardless of potential real estate risk, the most recent bank supervisory
stress tests found that the 35 largest banking organizations—representing about 80% of the banking
industry—are strongly capitalized and would be able to lend to households and businesses under the most
severe hypothetical scenario (Federal Reserve Board 2018a).
The thousands of smaller banks not included in the supervisory stress tests are mostly community banks that
serve businesses and residents in local banking markets. They tend to have a higher portfolio concentration
in real estate lending, and their loan portfolios are also less geographically diversified (FDIC 2012). Since
these banks are more likely to serve local borrowers who have limited alternative financing options, the

FRBSF Economic Letter 2019-10
banks’ own vulnerability could create a
negative feedback loop that substantially
tightens credit availability in some
communities (Berger and Udell 2002).

April 1, 2019
Figure 1
Ratios of real estate loans to assets in 2007 and 2017
Percent
100
75th percentile

90

History shows that the failure of a large
number of smaller depository institutions
over a short period of time, like the
Savings and Loan crisis in the 1980s, can
be disruptive to the overall financial
sector and economy. Furthermore, the
large number of bank failures in the late
1980s and early 1990s was in part
triggered by the collapse in commercial
real estate prices (Wheelock 2007), and
the 2008-09 global financial crisis
followed the bursting of the housing bubble.

50th percentile

80
70
60

2007:Q2

2018:Q3

50

25th percentile

2007:Q2

40

2018:Q3

30

2007:Q2

2018:Q3

20
10
0

Total real estate

Commercial real
estate

Residential real
estate

Figure 1 shows that bank portfolio concentration in real estate in 2017 looked broadly similar to its status at
the onset of the global financial crisis in 2007. The figure measures how much bank lending was
concentrated in real estate across more than 5,000 U.S. banks; the 50th percentile means that half of the
banks have higher concentrations and half have lower concentrations. The first two bars show that the ratio
of real estate lending to total assets rose from 33% to 37% for the 25th percentile, from 46% to 51% for the
50th percentile, and from 59% to 62% for the 75th percentile.
Breaking total real estate lending into residential and commercial components provides similar pictures,
with commercial concentrations falling slightly while residential concentrations rose slightly.
While real estate loan concentration today looks similar to its status at the onset of the global financial crisis,
banks have tightened their loan underwriting standards a great deal since then, as shown by the Federal
Reserve Senior Loan Officers Opinion Surveys conducted after the crisis (Federal Reserve Board 2018b).
Nevertheless, if real estate prices drop abruptly, do banks have sufficient capital to withstand it?

Capitalization
The banking industry is much better capitalized today than in 2007. The biggest improvement in
capitalization is among the largest banks, whose capital has more than doubled over the past 10 years. While
the buildup of bank capital since the financial crisis is most evident among large banking organizations, all
banking organizations are subject to new and improved capital standards that emphasize not only the
quantity but also the quality of bank capital. This improvement followed the enactment of the Dodd-Frank
Wall Street Reform and Consumer Protection Act in 2010 and U.S. banking regulators’ adoption of the Basel
Committee on Banking Supervision’s new capital standards (Basel III).
Regarding quantity, the new capital standard increased the level of capital requirements to ensure that banks
are sufficiently resilient to withstand losses in times of stress. It raised the minimum common equity from
2% to 4.5% of risk-weighted assets. In addition, banks are required to hold a capital conservation buffer
2

FRBSF Economic Letter 2019-10

April 1, 2019

comprising common equity of 2.5% of risk-weighted assets. If a bank’s common equity falls into the buffer
range, its discretionary capital distributions will be constrained to preserve capital.
Regarding quality, the new capital standard places a greater focus on going-concern, loss-absorbing capital
in the form of Common Equity Tier 1 (CET1) capital. It raised the composition of high quality CET1 capital in
meeting the total capital requirements under the new standard.

Estimated effects of real estate loan losses on bank capital
In general, a decline in real estate prices raises real estate loan delinquency, which is eventually written down
as loan losses. Despite that typical transmission mechanism, different banks are exposed to different types of
real estate lending in different parts of the country. A borrower’s decision to default depends not only on the
value of the underlying collateral but also other factors including cash flow, option values, and stigma.
Since the terms of bank lending and the specifics of loan workouts generally are not provided in publicly
available banking data, estimating the effects of falling real estate prices on individual bank performance is
quite challenging. As an alternative, I examine banks’ loss absorbing capacity, that is, CET1 plus Allowance
for Loan and Lease Losses to withstand real estate credit losses. Specifically, I address the question, will
hypothetical stress-induced losses in a bank’s real estate portfolio make the bank undercapitalized?
For this exercise, I collected bank-level financial statement data from the Reports of Condition and Income
(Call Reports) gathered by the Federal Financial Institutions Examination Council for those banks that were
not covered by the Federal Reserve stress tests. I use the real estate portfolio loss rates under the severely
adverse scenario in the 2018 Federal Reserve Dodd-Frank Act Stress Test, which assumed house prices fall
30%, and commercial real estate prices fall 40% by the third quarter of 2019. Under this scenario, the
supervisory estimates projected loss rates for first-lien mortgages was 2.7%, junior liens and home equity
lines of credit 4.9%, and commercial real estate loans 8.3% (Federal Reserve Board 2018a).
To determine whether the hypothetical stress losses could make a bank undercapitalized, I followed the
standard supervisory thresholds for bank capital adequacy. A bank is considered well capitalized by its
banking supervisor when the Tier-1 Risk-Based capital ratio is at least 8%, adequately capitalized when the
ratio is at least 6% but less than 8%, undercapitalized when the ratio is at least 4% but less than 6%, and
significantly undercapitalized when the ratio is less than 4%. While adequately capitalized banks are subject
to heightened supervisory scrutiny, undercapitalized institutions must file an acceptable capital restoration
plan with its regulator; they also cannot pay dividends or management fees, may not accept brokered
deposits, and may not solicit any deposits by offering substantially higher rates. Significantly
undercapitalized institutions face the same constraints plus limitations on executive compensation and other
restrictions deemed necessary by regulators.
A few caveats are in order. I do not intend this exercise to be comparable to a comprehensive stress test
where the entire bank balance sheet is stressed under a broad severe economic scenario. Rather, it is a
narrowly targeted exercise about the effects of a hypothetical real estate price decline on bank capital. Hence,
unlike the Fed’s stress test where the decline in real estate prices and a severe recession are assumed to take
place concurrently, this exercise is solely about a real estate price decline without a severe recession. Thus,
using the real estate scenario in the Fed’s stress test may exaggerate the real estate portfolio losses. By
3

FRBSF Economic Letter 2019-10
applying the aggregate loss rates to all
banks immediately, this exercise does not
take into consideration idiosyncratic
differences in each bank’s underwriting
standards, of which data is limited;
assuming an immediate hit to bank
capital instead of spreading the losses
over two years also denies banks the
possibility of making up some of the
losses through earnings.

April 1, 2019
Figure 2
Small estimated share of banks are undercapitalized
Percent of banking industry
10
9
8
7

Number of banks
Total assets

6
5
4

3
I apply the hypothetical loan loss rates to
1.37
2
the real estate portfolio of all banks not
0.54
1
covered by the Federal Reserve stress
0.2
0.06
0
tests. Figure 2 shows the portion of the
Significantly undercapitalized
Undercapitalized
banking industry by number of banks and
by percent of banking assets that would be undercapitalized: 72 banks (1.3%) would be undercapitalized and
15 banks (0.2%) would be significantly undercapitalized. Total assets of these 87 banks account for less than
1% of the banking industry.

For robustness, I also stress each bank’s entire loan portfolio using the aggregate supervisory estimate of
portfolio loss rates in the 2018 stress test: 8.3% for commercial real estate loans, 2.7% for first-lien
mortgages, 4.9% for junior-lien mortgages, 7.3% for commercial and industrial loans, and 14.4% for credit
card loans. Assuming an immediate hit to bank capital with the hypothetical stress losses to the entire
portfolio, 193 banks would be undercapitalized and 21 banks significantly undercapitalized. Total assets of
these 214 banks account for about 5% of the entire banking industry. To put these results into perspective,
between 1988 and 1991, a total of 1,656 FDIC-insured depository institutions either failed or received
assistance; together their total assets accounted for about 20% of the banking industry at that time.

Conclusions
Bank real estate loan concentration today looks broadly similar to that at the onset of the global financial
crisis. However, the banking system today should be more resilient due to the notable increase in both the
quantity and the quality of bank capital, especially among the largest banking organizations. Moreover, loan
underwriting standards have improved since the financial crisis. Assuming an immediate real estate portfolio
loss similar to the severity in the Fed’s stress tests of large banks, the simulation described in this Letter
shows that only a handful of small banks representing a small fraction of the industry would be significantly
undercapitalized.
Simon Kwan is a senior research advisor in the Economic Research Department of the Federal Reserve
Bank of San Francisco.

References
Berger, Allen N., and Gregory F. Udell. 2002. “Small Business Credit Availability and Relationship Lending: The
Importance of Bank Organizational Structure.” Economic Journal 112 (February), pp. 32–53.

4

FRBSF Economic Letter 2019-10

April 1, 2019

Brainard, Lael. 2018. “An Update on the Federal Reserve’s Financial Stability Agenda.” Speech at the Center for Global
Economy and Business, Stern School of Business, New York University, New York.
https://www.federalreserve.gov/newsevents/speech/brainard20180403a.htm
FDIC. 2012. FDIC Community Banking Study. Federal Deposit Insurance Corporation, December.
https://www.fdic.gov/regulations/resources/cbi/report/cbi-full.pdf
Federal Reserve Board of Governors. 2018a. “Dodd-Frank Act Stress Test 2018: Supervisory Stress Test Methodology and
Results.” June 2018 https://www.federalreserve.gov/publications/files/2018-dfast-methodology-results20180621.pdf
Federal Reserve Board of Governors. 2018b. “The July 2018 Senior Loan Officer Opinion Survey on Bank Lending
Practices.” August. https://www.federalreserve.gov/data/documents/sloos-201807-fullreport.pdf
Wheelock, David. 2006. “What Happens to Banks When House Prices Fall? U.S. Regional Housing Busts of the 1980s
and 1990s.” FRB St. Louis Review 88(5, September/October 88), pp. 413–430.
https://research.stlouisfed.org/publications/review/2006/09/01/what-happens-to-banks-when-house-prices-fall-us-regional-housing-busts-of-the-1980s-and-1990s/

Opinions expressed in FRBSF Economic Letter do not necessarily reflect the views of the management of
the Federal Reserve Bank of San Francisco or of the Board of Governors of the Federal Reserve System.
This publication is edited by Anita Todd with the assistance of Karen Barnes. Permission to reprint portions
of articles or whole articles must be obtained in writing. Please send editorial comments and requests for
reprint permission to Research.Library.sf@sf.frb.org

Recent issues of FRBSF Economic Letter are available at
https://www.frbsf.org/economic-research/publications/economic-letter/
2019-09

Rudebusch

Climate Change and the Federal Reserve
https://www.frbsf.org/economic-research/publications/economic-letter/2019/march/climatechange-and-federal-reserve/

2019-08

Paul

Modeling Financial Crises
https://www.frbsf.org/economic-research/publications/economic-letter/2019/march/modelingfinancial-crises/

2019-07

Hale /
Hobijn /
Nechio /
D. Wilson
Hale /
Lopez /
Sledz /

Inflationary Effects of Trade Disputes with China
https://www.frbsf.org/economic-research/publications/economicletter/2019/february/inflationary-effects-of-trade-disputes-with -china/

Inflation: Stress-Testing the Phillips Curve
https://www.frbsf.org/economic-research/publications/economic-letter/2019/february/inflationstress-testing-phillips-curve/

2019-04

Jordà /
Marti /
Nechio /
Tallman
Cúrdia

2019-03

Li

Nonmanufacturing as an Engine of Growth
https://www.frbsf.org/economic-research/publications/economicletter/2019/january/nonmanufacturing-as-engine-of-growth-via-creative-destruction/

2019-06

2019-05

Measuring Connectedness between the Largest Banks
https://www.frbsf.org/economic-research/publications/economicletter/2019/february/measuring-connectedness-largest-banks/

How Much Could Negative Rates Have Helped the Recovery?
https://www.frbsf.org/economic-research/publications/economic-letter/2019/february/howmuch-could-negative-rates-have-helped-recovery/